Joanne C. Austin - Page 4

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          handed to the front desk clerk of the Days Inn with the                     
          understanding that the envelope would be picked up later that day           
          by FedEx; that the front desk clerk placed the envelope in the              
          hotel’s “pickup box”; and that, upon returning to the hotel after           
          the trade show later that day, she inquired about the envelope              
          and was told by a front desk clerk that the “pickup box” was                
          empty.  In sum, petitioner asserts that “There was no reason for            
          me to think that my FEDEX package had not been picked up on the             
          8th.”                                                                       
               This matter was called for hearing at the Court’s motions              
          session in Washington, D.C.  Counsel for respondent appeared and            
          offered argument in support of respondent’s motion to dismiss.              
          In contrast, there was no appearance by or on behalf of                     
          petitioner, nor did petitioner file a statement pursuant to Rule            
          50(c), the provisions of which were explained in the Court’s                
          order calendaring respondent’s motion for hearing.                          
                                     Discussion                                       
               The Tax Court is a court of limited jurisdiction, and we may           
          exercise our jurisdiction only to the extent authorized by                  
          Congress.  Naftel v. Commissioner, 85 T.C. 527, 529 (1985).  This           
          Court’s jurisdiction to redetermine a deficiency depends on the             
          issuance of a valid notice of deficiency and a timely filed                 
          petition.  Rule 13(a), (c); Monge v. Commissioner, 93 T.C. 22, 27           
          (1989); Normac, Inc. v. Commissioner, 90 T.C. 142, 147 (1988).              






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